Foreword

Health Canada is committed to protecting personal information as well as confidential business information that is under its control. Ensuring the confidentiality, integrity, and availability of information is essential to government decision making and the delivery of services and Health Canada recognizes that the protection of this information is an essential element in maintaining public trust in government. Health Canada has a systematic process in place to protect this information including the identification and categorization of information, implementation of appropriate privacy training for personnel and information technology safeguards consisting of restricting access, including the level of access, to information in the Cannabis Tracking and Licensing System (CTLS) to those who need access to perform their duties. There may be instances where personal and/or confidential business information contained in applications made to Health Canada may be disclosed, however only as required or permitted by law. For example, data and/or contact information may be shared with Statistics Canada under the Statistics Act. The Statistics Act provides Statistics Canada with the legal authority to obtain administrative data for use in its statistical programs and also requires the agency to maintain the confidentiality of the collected data.

In addition to protecting your personal information, the Privacy Act gives you the right to request access to and correct your personal information. For more information about these rights, or about our privacy practices, please contact Privacy Coordinator at 613-946-3179 or HC.privacy-vie.privee.sc@canada.ca. You also have the right to file a complaint with the Privacy Commissioner of Canada if you think your personal information has been handled improperly.

Disclaimer:
This document should be read in conjunction with relevant sections of the Cannabis Act and its Regulations. In the case of any discrepancies between this document and the Cannabis Act and its Regulations, the latter shall prevail. In cases of discrepancy between the Cannabis Tracking and Licensing System (CTLS) and the Regulations or guidance, the Cannabis Regulations and this guide should be referred to for the established requirements and terminology.

This publication may be reproduced for personal or internal use only without permission provided the source is fully acknowledged.

Cat.: H14-262/1-2018E-PDF
ISBN: 978-0-660-27238-2
Pub.: 180180

1.0 Purpose

This document (the “Guide”) provides information on the process for provincial and territorial authorities to submit monthly reports to Health Canada as required under the Cannabis Act, its Regulations and any associated Ministerial order.

2.0 Background

The Cannabis Act and its Regulations provide, among other things, the framework to provide legal access to cannabis and to control and regulate its production, distribution and sale.

The oversight of the cannabis supply chain is a shared responsibility across many federal, provincial and territorial departments, industry and other stakeholders. One of Health Canada’s responsibilities is to track the flow of cannabis as a means of preventing the illegal inversion and diversion of cannabis into and out of the regulated system. Under this tracking system, a provincial or territorial public body that is authorized to sell cannabis or that is responsible for authorizing the sale of cannabis under a provincial Act is required to submit monthly reports to Health Canada.
This document provides guidance on the monthly reporting requirements. To maintain consistency and transparency, this Guide will be updated, as required, to reflect changes to policies.

Health Canada has other guidance documents and information on its website that may be used in conjunction with this document to assist provincial and territorial authorities in submitting their reports. The website is subject to on-going update and improvement.

3.0 Scope

This Guide applies to provincial or territorial authorities designated to submit monthly reports to Health Canada under the Cannabis Act, its Regulations and any associated Ministerial Order, covering the activities of individuals authorized to sell cannabis pursuant to a provincial Act under subsection 69(1) of the Cannabis Act, namely:

4.0 Definitions

The Cannabis Act, its Regulations and any associated ministerial order should be referred to for definitions. The definitions in this section are provided for greater clarity and reference.

Cannabis Tracking and Licensing System (CTLS): The name of the web-based application and case management system, established and maintained by Health Canada, through which applicants may apply for a cannabis licence to be issued by Health Canada and through which monthly tracking requirements must be submitted.

Reporting level access: The access level of individuals registered in the CTLS who are authorized to submit monthly reports.

4.1 Interpretation of data entry requirements

The terms and descriptions in this section are provided for greater clarity and reference, and are only to be used for the purposes of interpreting the data entry requirements into the CTLS.

Site: In respect of a holder of a licence, an area that is used exclusively by the holder and that consists of at least one building or one part of a building.

Cannabis product: Cannabis of only one of the classes that are set out in Schedule 4 to the Act – or a cannabis accessory if that accessory contains such cannabis – after it has been packaged and labelled for sale to a consumer at the retail level, but does not include a drug containing cannabis.

Finished cannabis inventory: The quantity of cannabis products. Quantities refer to cannabis only and should not include packaging or accessories. The classes of cannabis that may be cannabis products are those listed in Schedule 4 of the Cannabis Act (i.e., seeds, plants, dried cannabis, fresh cannabis, cannabis oil). By design, distributors and retailers will only record finished cannabis inventory.

Unfinished cannabis inventory: The quantity of cannabis other than cannabis contained in a cannabis product. The classes of cannabis mirror those in finished cannabis inventory, plus “other” for cannabis classes not listed in Schedule 4 of the Cannabis Act (e.g., edibles or concentrated products developed for research purposes and not intended for sale).

Opening inventory: The amount held in inventory on the first day of the reporting period.

Returns: Cannabis that was previously sold/purchased and distributed to/from another licence holder or a consumer at the retail level and subsequently returned.Cannabis sent off-site for testing or processing and subsequently returned to the same licence holder should be recorded as distributions to/from the applicable class of licence.

Destroyed: Cannabis that has been destroyed on-site, or sent for destruction off-site.

Other: In the context of the movement of cannabis, “other” is additions to or reductions from inventory that are not applicable toany other category. In the context of cannabis, it means cannabis classes not listed in Schedule 4 of the Cannabis Act (e.g., edibles or concentrated products developed for research purposes and not intended for sale).

Sales – non-medical to distributor/retailer: Means sales of cannabis products to a provincially authorized seller. This can be from a federal licence holder to a distributor/retailer, or from a distributor/retailer to another distributor/retailer.

Sales – non-medical online: Means sales to consumers at the retail level who were not present at the location at the time of purchase. This includes sales made online or by phone even if the cannabis product was picked up by the consumer in-store. Federal licence holders who ship cannabis on behalf of a provincial or territorial authority directly to a consumer at the retail level who placed an order through a provincial or territorial online system should record this as a non-medical direct-to-consumer online sale. The provincial/territorial distributor would not record this type of transaction through the CTLS.

Sales—non-medical retail: Sales to consumers at the retail level who were present at the location at the time of purchase.

Employees: Persons who, during the reference period, were employed at the reporting facility, regardless of the number of hours worked. This includes contractors and agents.

Management: Includes senior and middle management employees.

Administrative: Includes financial and business services, administration and clerical supervision, and support services employees.

Sales: Includes retail and wholesale sales, and customer service employees.

Production: Includes supervisory, production and general labour employees.

Other: Includes all other employees

The following symbols are used in this guide to highlight specific information.

Important: Key or cautionary information.

Supplementary information: Additional information such as quotes and legal references.

Tip: Information that could be helpful to the submitter.

5.0 Pre-reporting considerations

Before reporting, there are a number of areas that an individual designated to submit information should be familiar with in order to be compliant with the Cannabis Act, its Regulations and any associated Ministerial order, as well as other federal, provincial and territorial legislation. In addition, there are some activities that should be completed before submitting a monthly report.

Designated individuals are responsible for ensuring compliance with any ministerial order authorizing the Cannabis Tracking System.

Cannabis Tracking and Licensing System (CTLS)

All reports must be submitted using the CTLS. As such, designated individuals should be familiar with the use of the CTLS. For more information, refer to the CTLS Getting Started Guide. A copy of the guide can be requested from cannabis@canada.ca.

5.2 Actions prior to reporting

In addition to being familiar with the general knowledge areas in 5.1 and ensuring that all reporting requirements can be met, the following actions must be completed prior to submitting a monthly report.

5.2.1 Creating an account in the CTLS

Reports must be submitted through the CTLS. As such, a designated individual should be registered and familiar with the use of the CTLS.

5.2.2 Gaining reporting level access in the CTLS

Reporting level access is required of individuals submitting monthly reports. In the case of designated provincial and territorial authorities, reporting level access must be requested directly along with the appropriate documentation. To do so, please send an email to hc.ctls-bi-sscdl-ie.sc@canada.ca. In the subject line include “Reporting Level Access Request”. In the body of the email, include your full name and the province or territory for which you will be reporting. An officer will then reply with a request to complete a Reporting Level Access Request Form. Once the required information is submitted via this form, an officer will verify the information and inform you once your access level has been changed and you have been assigned to a province or territory.

6.0 How to submit a report

Individual reports must be submitted for each licensed site. To do so, designated individuals have two options in the CTLS:

Manual entry

.csv file upload

Each process is explained below.

Tip: A single .csv file can be uploaded for all distribution and retail locations within a province or territory. Each location's information must be included on a separate row of data.

Important: Do not select the month in which you are submitting the report (which is typically the month following the reporting period). InformationImportant: The "Province / Territory" information for the location you are reporting for will be prepopulated based on your user profile.

Step 4: Select the following. Type: Select whether you are reporting on behalf of a retail or a distribution establishment.

Site ID: Enter the unique identifier (e.g., store number) associated with the retailer or distributor above.

NOTE: The structure is not prescribed, but recommended as being PT#### (e.g., BC0002)

City: Enter the name of the city/town/municipality in which the retailer/distributor is located. If no city/town/municipality, you may indicate the postal code of the establishment.

Important: Note that, in English, commas should not be used to separate 1000's. For example, 9,999.999 should simply be inputted as 9999.999. If not, the figure will be erroneously recorded as 9.999. In French, commas must be used as a decimal point when uploading through the French portal. For example, the same figure above should be recorded as 9999,999.

Step 8: Click the "Save Seeds data" button

Important: Do not click the "Next" button until all applicable tabs and fields in "Inventory" have been filled and saved.

Step 11: Record all your Seed sales by Sales Channel.
Important: In cases where non-medical online orders are placed through a provincial or territorial online system but shipped directly to a consumer at the retail level by a federal license holder, the provincial/territorial distributor would not record this type of transaction through the CTLS.
Instead, it would be recorded by the federal license holder.
Step 12: Click the "Save Seeds data" button.

Information: Employees: are persons who, during the reference period, were employed at the reporting facility, regardless of the number of hours worked. This includes contractors and agents.

Management: Includes senior and middle management employees.

Administrative: Includes financial and business services, administration and clerical supervision and support services employees.

Sales: Includes retail and wholesale sales, and customer service employees.

Production: Includes supervisory, production and general labour employees.

Other: Includes all other employees.

Step 16: Once all tabs in "Business Statistics" have been input, click the "Save & Next" button to move to "Submission".

Employee numbers are voluntary.

You will see the following screen appear:

Screenshot 12: SubmissionScreenshot 12 - Text description

Information: I hereby attest that I have the authority to submit this report on behalf of the legal entity associated with this account. I hereby attest that all of the information and documents submitted in regards to this report are, to the best of my knowledge, correct and complete.

Step 17: Read the "Attestation" and click the "Submit" button to complete the reporting submission process.

6.2 Option 2: File upload

A single .csv file can be uploaded for all distribution and retail locations within a province or territory. Each location’s information must be included on a separate row of data. Files uploaded in the CTLS must conform exactly to specifications prescribed by the system. See Appendix 1 for the data specifications for provincial and territorial inventory reports. Be sure to check the website for updates.

Information: I hereby attest that I have the authority to submit this report on behalf of the legal entity associated with this account. I hereby attest that all of the information and documents submitted in regards to this report are, to the best of my knowledge, correct and complete.
Step 3: Click the "Browse" button to select a file for upload.
Important: Note: Different web browsers may have slightly different layouts.
Step 4: Once the file is selected, click the upload icon the upload the file to Health Canada.
Information: Uploaded files appear below "Document Name" in the table, which cannot be accessed for further editing. See Section 7.0 on "How to make corrections to a previously submitted report".

If your file was uploaded successfully, you will see the following message:

Screenshot 3: SuccessScreenshot 3 - Text description

Your document has been successfully uploaded. Please refresh the page in a few minutes to view your uploaded document in the table below.

7.0 How to make corrections to a previously submitted report

Once a report has been successfully submitted, it cannot be re-opened for further editing. If a correction to a previously submitted report is required, send a request to hc.ctls-bi-sscdl-ie.sc@canada.ca. Be sure to include “CTLS Reporting” in the subject line to ensure your request is directed to the appropriate subject matter expert. Provide as many details as possible and include the report ID and site ID of the distributor/retailer in question in the body of the message, as well as your contact information. A Health Canada officer will contact you either by phone or by email to discuss the required correction. For minor corrections, the officer can make the corrections directly in the system on your behalf. For more substantive corrections, the officer can make a manually-submitted report available in the Draft Cannabis Tracking Reports section in the CTLS, which will then allow you to make the necessary corrections and resubmit the report. However, if major corrections are required to a report that was submitted via file upload, the officer must first invalidate the original report and you will then be required to submit a new report for that particular location and reporting period. The decision to make the correction directly or to make the report available for resubmission will be made at the discretion of the officer. Note that all corrections will have an audit trail for future verification/investigation if necessary.

8.0 FAQs

To minimize system risks and assure data quality, only employees granted reporting level access will be authorized to submit reports in accordance with the Policy on Government Security and its Standard on Identity and Credential Assurance. Note that others in your organization can prepare the .csv document for upload by employees granted reporting level access.

8.2 How should goods in transit be recorded?

Goods in transit at time of reporting should be accounted for based on the shipping terms associated with the goods, which are either:

FOB shipping point. If the shipment is designated as freight on board (FOB) shipping point, ownership transfers to the buyer as soon as the shipment departs the seller.

FOB destination. If the shipment is designated as freight on board (FOB) destination, ownership transfers to the buyer as soon as the shipment arrives at the buyer.

8.3 How should I record sales to customers that ordered through a provincial or territorial online system but whose orders were shipped to them directly by a federal licence holder?

Online purchase orders registered by a distributor or retailer but shipped directly to a consumer at the retail level by the federal licence holder should be recorded as a non-medical online sale by the federal licence holder. The distributor or retailer should not record the sale.

9.0 Other things to note

In addition to the FAQs, please ensure your reports are accurate by avoiding these common reporting errors:

Opening inventory should equal the closing inventory of the previous month for each product class.

There should never been negative closing inventories.

Cannabis oil volume should be recorded as the volume of cannabis oil only, net of any packaging or encapsulation material. The unit of measure is litres.

Cannabis weight should be recorded in kilograms, not grams.

10.0 For more assistance

If you have questions regarding the submission of monthly reports through the CTLS, email hc.ctls-bi-sscdl-ie.sc@canada.ca. Include CTLS Reporting in the subject line to ensure your request reaches the right person.

If your request pertains to an error received during the submission process, provide as many details as possible including screen shots and, in the case of a file upload, a copy of the .csv file you attempted to submit.